Other definitions and rules
For purposes of this subsection—
(A) Related person
(A)Related person#
The determination of whether a person is related to another person shall be made in the same manner as under subsection (e)(4).
(B)Election#
(i) In general An election under this subsection with respect to any applicable debt instrument shall be made by including with the return of tax imposed by chapter 1 for the taxable year in which the reacquisition of the debt instrument occurs a statement which— (I) clearly identifies such instrument, and (II) includes the amount of income to which paragraph (1) applies and such other information as the Secretary may prescribe.
(ii) Election irrevocable Such election, once made, is irrevocable.
(iii) Pass-thru entities In the case of a partnership, S corporation, or other pass-thru entity, the election under this subsection shall be made by the partnership, the S corporation, or other entity involved.
(B)(i)In general#
An election under this subsection with respect to any applicable debt instrument shall be made by including with the return of tax imposed by chapter 1 for the taxable year in which the reacquisition of the debt instrument occurs a statement which—
(I) clearly identifies such instrument, and
(II) includes the amount of income to which paragraph (1) applies and such other information as the Secretary may prescribe.
(B)(i)(I)#
clearly identifies such instrument, and
(C)Coordination with other exclusions#
If a taxpayer elects to have this subsection apply to an applicable debt instrument, subparagraphs (A), (B), (C), and (D) of subsection (a)(1) shall not apply to the income from the discharge of such indebtedness for the taxable year of the election or any subsequent taxable year.
(D)Acceleration of deferred items#
(i) In general In the case of the death of the taxpayer, the liquidation or sale of substantially all the assets of the taxpayer (including in a title 11 or similar case), the cessation of business by the taxpayer, or similar circumstances, any item of income or deduction which is deferred under this subsection (and has not previously been taken into account) shall be taken into account in the taxable year in which such event occurs (or in the case of a title 11 or similar case, the day before the petition is filed).
(ii) Special rule for pass-thru entities The rule of clause (i) shall also apply in the case of the sale or exchange or redemption of an interest in a partnership, S corporation, or other pass-thru entity by a partner, shareholder, or other person holding an ownership interest in such entity.
(D)(i)In general#
In the case of the death of the taxpayer, the liquidation or sale of substantially all the assets of the taxpayer (including in a title 11 or similar case), the cessation of business by the taxpayer, or similar circumstances, any item of income or deduction which is deferred under this subsection (and has not previously been taken into account) shall be taken into account in the taxable year in which such event occurs (or in the case of a title 11 or similar case, the day before the petition is filed).
(D)(ii)Special rule for pass-thru entities#
The rule of clause (i) shall also apply in the case of the sale or exchange or redemption of an interest in a partnership, S corporation, or other pass-thru entity by a partner, shareholder, or other person holding an ownership interest in such entity.